What USAC wants to say is: "Include all the incoming lines on a bill, not just the billed telephone number." I've never heard a phone company call an incoming line of any sort an "extension." In telecomese, "extension" means an internal line connected to a phone system, not an external line. In the case of Centrex, it's not confusing, but otherwise it's going to be the wrong number.

It brings up an interesting question, though. In the traditional world, you either had a bunch of phone lines (POTS or Centrex) or a PRI. (What's a PRI, you ask? It's an Integrated Service Digital Network (ISDN) Primary Rate Interface, a T-1 channelized into 24 channels, meaning up to 24 simultaneous calls. You can associate as many phone numbers as you wanted to that trunk by buying blocks of DID (Direct Inward Dialing) numbers. You have to have your own PBX to distribute the calls coming in over the PRI.)

Determining the number of lines was straightforward. In the case of POTS or Centrex, you put down the total number of lines on the bill. (Tip for figuring out the total number: Most bills have a dizzying array of different types of lines, but there is frequently only one line for "SLC" or "Subscriber Line Charge", sometimes called "FCC SLC" or "FCC line charge" or some other misleading name to make you think it's some kind of tax, when in fact the FCC's involvement is to set the maximum amount that can charged; the phone company is keeping 100% of that money. So if you find that line on the bill, it will typically show you how many lines there are total.) In the case of PRI, you put down the number of channels you're using (almost always 24). Don't put down the number of DIDs.

Along comes VoIP. There is an architecture analogous to the PRI, called SIP (Session Initiation Protocol) trunks. You need a PBX to use SIP trunks, and you buy a certain number of trunks (simultaneous calls), so it's easy to determine the number of "lines" (though in reality it's only one line with a bunch of conversations crammed into it, but that's kind of true for PRIs, too). And vendors offer another service that looks just like regular Centrex: you get as many phone jacks as you want, and you can connect them to regular phone lines; the provider installs a router in your building converting those phone calls to VoIP. If you want, you can have IP phones in your building, in which case the provider router doesn't have to convert calls, it just routes the IP packets from your phone. Like with Centrex, you pay a certain amount per phone each month. And like with Centrex, all call processing takes place on service provider equipment.

In all of those scenarios, it's clear how many "lines" you have. Either the number of SIP trunks if you have a PBX or the number of phones if you are using the Centrex-like setup.

But there is a new option on the scene that makes the number of lines fuzzy. It's just like the scenario above, where you have VoIP phones connected to a service provider who handles all the calls. The difference is that the service provider charges you for simultaneous calls. This can be an attractive option for schools, since they typically have hundreds of phones in classrooms which get used very rarely. So a school with 200 phones can probably get by with 12 simultaneous calls, which is a lot cheaper.

But how many lines do you have? I mean, each and every phone, when you pick up the handset, interacts directly with the service provider to set up the call. So our hypothetical school has 200 lines. But if 12 people are on the phone, the 13th person can't make a call. So is that 12 lines? Adding to the confusion is that the limit of 12 calls is a setting in the service provider's software. In reality, the 13th call does reach the service provider's switch, which makes the decision that the school is over it's limit, and gives back a busy signal.

So you'd think 12 lines, but the only difference between a school paying $30/month for each phone set and the school paying $600/month for 12 simultaneous calls is a software setting and maybe once or twice a month someone is the unlucky 13th caller and gets a busy signal.

I guess the right answer in that case really is 200 lines, even though they can't all make calls at the same time. So now the USAC guidance is right.

Wednesday, February 22, 2012

Much as I like to grumble, I also like to herald improvements, and yesterday I learned of one. While I was knee-deep in last-minute Form 470 nonsense, a colleague in the office said she tested the online Item 21 Attachment tool, and she is able to create the attachments before the Form 471 is submitted.

To normal humans, this is completely unimportant, but as I've said before, I found it frustrating that we couldn't even start the attachments before the 471 was done. Perhaps my protestations did not fall on deaf ears.

Why is it important? Convenience aside, I have always considered it best practice to complete the Item 21 Attachments before submitting the Form 471, because every now and then you catch an error while doing the attachment, and you can fix the 471 before submitting.

It's been a while since I went on a linguistic rant, and I've got a curmudgeonly persona to maintain here, so I need to whine about something. To wit:

The term "Item 21 Attachment" is just ungainly. It is not an attachment to Item 21 exactly, although Item 21 is the place on the form where you identify the number of the attachment. I think it should be a "Block 5 Attachment" or a "Form 471 attachment." (OK, really I think it should be part of the Form 471, not an attachment: the forms should be as complicated as they have to be to make clear the complexity of the program, and it just seems a little sleazy that somehow they're getting away with information collection without creating a form and going through OMB and all by calling it an attachment. But back to my original rant.)

But the real nettle in my shoe is that since "Item 21 Attachments" takes too long to say, people who spend too much time with this program commonly call them "Item 21s." OK, first off, that's like deciding "CD players" is too wordy, and calling them "CDs"; the meaning is lost. If you want to drop part of "Item 21 Attachment," drop "Item 21" and just call them "Attachments." It's not like there are any other attachments in the E-Rate program. I mean, it's like not wanting to say "flat-screen TV" and just calling it a "flat-screen." What's that? People do? Oh, our society is just falling apart. (I was going to use "trash collector" and "trash," but decided that was too disrespectful to our sanitation engineers, and in NJ, you do not want to cross those guys.)

In addition, it should be "Items 21" not "Item 21s." It's like people talking about Form 470s; it should be Forms 470. (And don't get me started on people who put apostrophes and make it Form 470's, unless you're making a possessive like "this Form 471's Item 21 Attachments.") Maybe it's just because of all the Downton Abbey I'm watching, but if we're going to misabbreviate, let's at least do it in a way that sounds proper. Of course, it's not really any more proper, since it is neither the "Item" nor the "21" that is being made plural, it's the "attachment," but we dropped that part of the name, so we're screwed. But "Items 21" still sounds more like something the Dowager Countess would say.

Friday, February 10, 2012

So Wednesday the FCC denied 23 appeals because they were filed late. I'm not saying that any of the appeals should be granted, and I agree the FCC has to put its foot down at some point. I just find it amusing that only 2 of the 23 appeals was decided within 90 days, as required by FCC regulation.

Let's make a new rule: the FCC cannot deny appeals for being filed late if the decision is filed too late.

Snarkiness aside, these appeals actually follow the trend of more timely appeal decisions from the FCC. The vast majority of the appeals were from 2011, which is much quicker turnaround than I'm used to.

Thursday, February 02, 2012

Just a little tidbit from the latest USAC Board meeting in DC (courtesy of Funds for Learning): "The SLD reported to the Board that they anticipate the final FY2011 P2 threshold to be 87%...." Given the FCC's willingness to upend the funding landscape willy-nilly, I'm surprised the SLD is even making estimates any more.

The second half of the sentence I quoted in the opening: SLD "did not make an official recommendation to drop the threshold below its current 90% level.." So here we are, more than halfway through the year, and we still haven't even moved the denial threshold below 90%. So far from my dream of setting the P2 threshold before the start of the funding year.

So what should the FCC do right now? Well, it's a little late, but they should set the denial threshold for FY 2011 at 90%. That would allow applicants with discounts less than 90% to fling up repeat P2 requests for 2012. Then set the denial threshold for 2012 right now. Be conservative, set it at 88%. See how that goes, and gradually the FCC will be able to set the denial threshold when they release the Eligible Services List. Imagine.

About Me

Involved with the E-Rate program since 1997, On-Tech's president, Dan Riordan, has continuously assisted schools and libraries in obtaining E-Rate funding, first as a trainer, then as a district employee, and now as an E-Rate consultant.